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© 2014 Grant Thornton LLP. All rights reserved.
Is Your Company Prepared?
Tangible Property Regulations &
International Tax Developments Impacting
Multinational Companies
FEI Silicon Valley
April 28, 2015
© Grant Thornton LLP. All rights reserved.
Washington Update: Tax legislative landscape
Donald A. Corbett
Tax Practice Leader
Grant Thornton LLP
April 28, 2015
© Grant Thornton LLP. All rights reserved.
© Grant Thornton LLP. All rights reserved.4
Agenda
• Where are we now?
• Where are we going?
© Grant Thornton LLP. All rights reserved.
December 2014 Legislation
• Congress waited until the last minute again, but
passed some legislation:
– ABLE Act
– A spending bill
– Tax Extenders
© Grant Thornton LLP. All rights reserved.
ABLE Act
• ABLE Act:
– Creates 529-style plans for disabled individuals
• Offsets:
– Adjusts failure to file penalties for inflation
– Raises inland waterways fuel tax rate to 29 cents
– Increases Medicare provider levies to 30%
– Excludes CFC dividends from personal holding
company income
© Grant Thornton LLP. All rights reserved.
Spending Bill (aka the CROmnibus)
• Omnibus spending bill approved before year-end:
– Funds government for FY2015
– Extends Internet Tax Freedom Act
– $346M budget cut for IRS
– Expatriates no longer need to maintain health
coverage via ACA
– Allows distressed multi-employer pensions to
reduce benefits
© Grant Thornton LLP. All rights reserved.
Extenders
• Expired provisions extended in December:
– Retroactive extension of over 50 provisions that
expired at the end of 2014
– Technical corrections
– Increase in refund threshold for C Corporation JCT
review from $2 million to $5 million
• One little problem:
– All of the extender provisions are now expired again
for 2015!
© Grant Thornton LLP. All rights reserved.
Congress has a bad track record in passing timely
tax legislation
© Grant Thornton LLP. All rights reserved.
Deadlines
• Congress has some deadlines to contend with:
– May 31 – Federal Highway Trust funding expires
– June 30 – Export/Import Bank Charter extension ends
– End of June: SCOTUS decision in King v. Burwell
expected
– August 15 – 1st GOP Presidential Debate
– September/October – Treasury "extraordinary
measures" run out, default if debt ceiling is not lifted
© Grant Thornton LLP. All rights reserved.11
Tax reform in 2015?
• Comprehensive tax reform is dead
– Obama unwilling to negotiate on lower individual rates.
– Hatch and Ryan admit they can't achieve an individual
rate cut
• Will Hatch and Ryan agree to corporate-only reform?
– Asking pass-throughs what they would accept short of a
rate cut.
• Enhanced Secs. 179, 199, etc.
– Grant Thornton has advocated for a "business
equivalency rate"
© Grant Thornton LLP. All rights reserved.
© Grant Thornton LLP. All rights reserved.13
Business Equivalency Rate
• Allow active business income to be taxed at the
same rate, whether earned by a C corporation or a
pass-through.
© Grant Thornton LLP. All rights reserved.14
Tax reform in 2015?
• Congressional taxwriters have limited time
remaining, as Presidential campaigns kick-off.
• Can Hatch and Ryan get enough of Congress on
board to enact corporate-only tax reform?
• Ryan is willing to wait until 2017 for a new
president to work on individual rates.
– But will the new president share his beliefs?
© Grant Thornton LLP. All rights reserved.15
Agenda
• Where are we now?
• Where are we going?
© Grant Thornton LLP. All rights reserved.
Dynamics will be different in 2016
© Grant Thornton LLP. All rights reserved. 17
Wait until 2017?
• GOP may have their hands full in 2016
– Presidential election year favors Democrats
• Have won 5 of 6 last elections by popular vote
– Electoral map favors Democrats
• Republicans won big in 2014, but have to
defend many more Senate seats than
Democrats
• Some of those Republican seats are in blue /
swing states that tend to vote Democratic
© Grant Thornton LLP. All rights reserved.18
Wait until 2017?
Problem:
• GOP defends
24 Senate
seats in 2016
• Dems just 10
© Grant Thornton LLP. All rights reserved.19
Is there anything Congress can do in 2015?
• Bipartisan House vote on taxpayer rights
– Enactment possible, but uncertain
• House passed repeal of estate tax while
maintaining basis step-up at death
– Highly unlikely to be enacted into law.
• Medical Device Excise Tax repeal?
– Hatch pushing for it, but this is ACA provision,
which Obama will fight for
© 2014 Grant Thornton LLP. All rights reserved. 20
Questions?Comments?
© 2014 Grant Thornton LLP. All rights reserved.
International tax: Changes impacting technology companies
© 2014 Grant Thornton LLP. All rights reserved. 22
Randy Free
Partner, West Region
International Tax Practice
Leader
949.608.5311
randy.free@us.gt.com
Allan Smith
Partner, International Tax
408.216.8540
allan.smith@us.gt.com
PresentersToday's
© 2014 Grant Thornton LLP. All rights reserved. 23
Agenda
• Global Stage – Summary of global trends
impacting international tax law
• OECD BEPS Action 1 Overview
• FATCA
• Financial Statement Implications
© 2014 Grant Thornton LLP. All rights reserved. 24
Learning objectives
• Identify international tax developments impacting multinational companies
• Demonstrate how to address the shifting tax landscape for tax planning and manage the financial statement implications of foreign earnings
© 2014 Grant Thornton LLP. All rights reserved. 25
In the news: A global issue
"FACTS ARE THE ENEMY OF TRUTH"
- Don Quixote de la Mancha
© 2014 Grant Thornton LLP. All rights reserved. 26
In the news: A global issue
PM TURNS TO TAX AS VIC FALLS
© 2014 Grant Thornton LLP. All rights reserved. 27
In the news: A global issue
PM TURNS TO TAX AS VIC FALLS
BRITAIN TO TARGET GLOBAL TAX DODGERS
© 2014 Grant Thornton LLP. All rights reserved. 28
In the news: A global issue
PM TURNS TO TAX AS VIC FALLS
BRITAIN TO TARGET GLOBAL TAX DODGERS
TAX COALITION SEEKS ACCORD
© 2014 Grant Thornton LLP. All rights reserved. 29
In the news: A global issue
PM TURNS TO TAX AS VIC FALLS
BRITAIN TO TARGET GLOBAL TAX DODGERS
TAX COALITION SEEKS ACCORD
NO PATIENCE FOR INDECISIVE GOVERNMENTS
© 2014 Grant Thornton LLP. All rights reserved. 30
In the news: A global issue
PM TURNS TO TAX AS VIC FALLS
BRITAIN TO TARGET GLOBAL TAX DODGERS
TAX COALITION SEEKS ACCORD
NO PATIENCE FOR INDECISIVE GOVERNMENTS
POLICY HURDLES STUNT INDIA'S GROWTH
© 2014 Grant Thornton LLP. All rights reserved. 31
In the news: A global issue
PM TURNS TO TAX AS VIC FALLS
TAX COALITION SEEKS ACCORD
NO PATIENCE FOR INDECISIVE GOVERNMENTS
POLICY HURDLES STUNT INDIA'S GROWTH
SLACK FRANCE NARROWLY AVOIDS EU BUDGET FINE
BRITAIN TO TARGET GLOBAL TAX DODGERS
© 2014 Grant Thornton LLP. All rights reserved. 32
In the news: A global issue
PM TURNS TO TAX AS VIC FALLS
BRITAIN TO TARGET GLOBAL TAX DODGERS
TAX COALITION SEEKS ACCORD
NO PATIENCE FOR INDECISIVE GOVERNMENTS
POLICY HURDLES STUNT INDIA'S GROWTH
SLACK FRANCE NARROWLY AVOIDS EU BUDGET FINE
GREECE REJECTS TAX RISES, INCOME CUTS
© 2014 Grant Thornton LLP. All rights reserved. 33
In the news: A global issue
PM TURNS TO TAX AS VIC FALLS
BRITAIN TO TARGET GLOBAL TAX DODGERS
TAX COALITION SEEKS ACCORD
NO PATIENCE FOR INDECISIVE GOVERNMENTS
POLICY HURDLES STUNT INDIA'S GROWTH
SLACK FRANCE NARROWLY AVOIDS EU BUDGET FINE
GREECE REJECTS TAX RISES, INCOME CUTS
US SET TO FIGHT IN LOOMING TAX WAR
© Grant Thornton LLP. All rights reserved. 34
Audience question 1
What is your biggest internal challenge in managing
the risks from the changing global tax landscape?
A. Agility in understanding and reacting to change
B. Utilizing technology to understand big data
C. Transparency and certainty in global compliance
D. None, as we’re prepared for the challenges
E. I don't know
© 2014 Grant Thornton LLP. All rights reserved. 35
What does all of this tell us?
Extreme pressure, by constituents and regulators, on governments to produce short-term economic growth from aggressive tax reform.
Asked about the G20 and OECD plan to get more tax out of multinationals…,Mr. Robason said: " Ultimately it won't work. It will be a race between countries to create an advantage for themselves. It will result in countries putting in their own tax laws."
This is a global phenomenon facing MNEs
© 2014 Grant Thornton LLP. All rights reserved. 36
Race between countries
• Brazil – Considering tightening existing rules
• Ireland – Abolition of Double Irish from 1/1/15
• France – Contemplating special rules,
aggressive stance against tax schemes
• Mexico – New requirements for deductibility of
cross border related party payments
• United Kingdom – Diverted Profits Tax
• U.K. & Germany – Substance in patent box
© 2014 Grant Thornton LLP. All rights reserved. 37
OECD/G20 BEPS Project
2013 OECD/G20 15 Point Action Plan to Address BEPS
2014 OECD/G20 Adopt 1st Set of Seven Deliverables
Action 1 – Tax Challenges of the Digital Economy
Define CollaborateInfluence
Dec 2015 OECD/G20 Harmonized Report
© 2014 Grant Thornton LLP. All rights reserved. 38
Permanent establishment (PE)
Under most domestic law and Articles 5 & 7 of the OECD Model Tax Convention, non-resident taxed only if it has a PE in that country.
• Technology allows interaction with customers w/o physical presence
Ensure core activities cannot inappropriately benefit from the exception form PE status
© 2014 Grant Thornton LLP. All rights reserved. 39
Transfer pricing of intangibles
The importance of intangibles, the use of data, and the spread of global value chains, is impacting transfer pricing
• Mobility of intangibles generates substantial BEPS opportunities
Ensure profits cannot arbitrarily be allocated to low tax / no-tax jurisdictions contractually
© 2014 Grant Thornton LLP. All rights reserved. 40
Characterization of digital income
New digital products, cloud computing and 3 D
printing raise income characterization questions
• Characterization of income impacts application
of both income and withholding taxes
Ensure proper classification and determination of
taxation rights
© 2014 Grant Thornton LLP. All rights reserved. 41
MNE Action Plan
41
• Assume transparency with tax officials
• Avoid commercial artificiality and treaty shopping
• Ensure tax/transfer pricing structures mirror substance
• Expect local country audits subject to local country
laws and interpretations of the arm’s length principle
and treaty clauses (especially in non-OECD countries)
and increased enforcement from all countries
• Consider the use of APAs as a risk-management tool
• Investigate efficient documentation processes
• Think governance and corporate reputation
© 2014 Grant Thornton LLP. All rights reserved. 42
Audience question 2
Of the following BEPS Action 1 deliverables, which one do
you think, even if viscerally, could have the most impact on
your company?
A. Redefining nexus and permanent establishment
B. Uncertainty regarding income characterization
C. Adaptation of the CFC rules
D. Evolving transfer pricing r/e use of intangibles
E. I'm unsure; I don't know
© 2014 Grant Thornton LLP. All rights reserved.
FATCA
© Grant Thornton LLP. All rights reserved.
Foreign Account Tax Compliance Act
(FATCA)
• FATCA works on top of the "traditional" chapter 3
withholding regime
• Withholding under chapter 3 addresses income that is paid
to someone who may not be filing a U.S. tax return
– example: royalty paid to licensor located outside the U.S.
• Withholding under FATCA addresses income that may not
be being reported by a U.S. taxpayer
– example: interest paid to foreign lender located outside the U.S.
© Grant Thornton LLP. All rights reserved.
FATCA's global reach
as of 12/31/2013
Model 1 IGA
Model 2 IGA
Jurisdiction that has in
substance reached Model 1
agreement
Jurisdiction that has in
substance reached Model 2
agreement
Countries with Intergovernmental Agreements
(IGAs)
© Grant Thornton LLP. All rights reserved.
FATCA's global reach
as of 2/13/2015
Model 1 IGA
Model 2 IGA
Jurisdiction that has in
substance reached Model 1
agreement
Jurisdiction that has in
substance reached Model 2
agreement
Countries with Intergovernmental Agreements
(IGAs)
© Grant Thornton LLP. All rights reserved.
FATCA's global reach
• U.S. companies need to assess which payments are subject to
withholding and ensure it fulfills new documentation and withholding
requirements
– Understand the types of payments potentially subject to FATCA
withholding (including intercompany payments)
– Assess whether any exceptions apply (e.g. ordinary course of business,
grandfathered obligations) and document
– Obtain and/or update required documentation (most commonly Form W-
8BEN-E)
• As part of this, U.S. companies may need to assist non-U.S. group
entities in determining FATCA status
© Grant Thornton LLP. All rights reserved.
FATCA's global reach
Determining FATCA status
• The universe primarily consists of foreign financial institutions (FFIs)
and non-financial foreign entities (NFFEs)
• In order to avoid FATCA withholding, NFFEs generally must either
disclose "substantial U.S. owners" or provide its FATCA status
certifying that it is not a "passive NFFE"
– commonly used statuses are publicly traded NFFE (and affiliates)
and "Active NFFE"
© Grant Thornton LLP. All rights reserved.
FATCA's global reach
Common Issues for Technology Companies
• Broad information requests from withholding agent
– Payments for the use of property (e.g. royalties) are not withholdable
payments for FATCA purposes
– Source of income should be considered
• Determining FATCA status for foreign holding companies can be
complex
– IP holding companies generating passive income may require additional
analysis
© Grant Thornton LLP. All rights reserved.
FATCA's global reach
Takeaways
• FATCA affects all companies making payments
• FATCA presents a good opportunity to run a systems check on
withholding procedures
– Withholding agents should analyze process and procedures will be
needed for identifying, withholding, paying, reporting and reconciling
accounts
– Foreign payees should analyze their FATCA status in order to position
themselves to fulfill any FATCA obligations and provide the appropriate
documentation to withholding agents or foreign financial institutions
© Grant Thornton LLP. All rights reserved.
Audience Question 3
What effect do you think FATCA will have on
your company?
A. Substantial, but we're ready
B. Potentially substantial, I'm concerned
C. Minimal
D. Does not apply or don't know
© 2014 Grant Thornton LLP. All rights reserved.
Financial statement
implications
© 2014 Grant Thornton LLP. All rights reserved. 53
Financial statement implications
• Transparency
• Risk management
© Grant Thornton LLP. All rights reserved. 54
Transparency
The issue
• Income tax information provided in the financial statements
may not be detailed enough for users to:
– Analyze earnings determined to be indefinitely reinvested in foreign
subsidiaries
– Determine what the tax effects of foreign earnings deemed to be
indefinitely reinvested would be if those earnings were repatriated to
the U.S. parent company
Source: Financial Accounting Foundation's Post-Implementation Review Report on FASB Statement
No. 109, Accounting for Income Taxes (November 2013)
© Grant Thornton LLP. All rights reserved. 55
Transparency
The magnitude
• Over $2 trillion of indefinitely reinvested foreign earnings of
the Russell 1000 with average annual increase of $204
billion during last 5 years (93% growth)
© Grant Thornton LLP. All rights reserved. 56
Transparency The magnitude with technology companies
• In the aggregate, the 100 companies in the S&P 100 index
hold approximately $1.4 trillion of the estimated $2 trillion of
permanently reinvested earnings (PRE), with technology
companies ($341 billion) and health care companies ($335
billion) having the most at stake
$341 $335
$171 $157
$146 $113
$52 $39 $38
$0 $50 $100 $150 $200 $250 $300 $350 $400
TECHNOLOGYHEALTH CAREINDUSTRIALS
CONSUMER STAPLESFINANCIALS
ENERGYCONSUMER DISCRETIONARY
MATERIALSCOMMUNICATIONS
PRE (in billions)
PRE (in billions)
© Grant Thornton LLP. All rights reserved. 57
Transparency The magnitude with technology companies
• In the last three years, the amount of indefinitely reinvested
foreign earnings:
– Has approximately doubled at Microsoft and Google
– Has nearly tripled at Apple
• In the five-year period from 2007-2013, the amount of
indefinitely reinvested foreign earnings increased by
427.8% at 10 major technology firms
– Apple, Cisco, Dell, Ebay, Google, Hewlett Packard, IBM, Intel,
Microsoft, and Oracle
© 2014 Grant Thornton LLP. All rights reserved. 5858
• The SEC's Division of Corporation Finance continues to
closely review corporate disclosures on the tax implications
associated with a company's overseas earnings
• A November 2014 statement by Mark Kronforst, chief
accountant, indicated that more SEC comment letters will be
issued inquiring into the disclosure practices of U.S.
businesses with foreign operations
Transparency
What is the SEC doing about it
© Grant Thornton LLP. All rights reserved. 59
• Recent SEC comment letters have:
– Challenged registrants when their indefinite reinvestment
assertions appear inconsistent with the parent's liquidity needs or
disclosures elsewhere in the registrant's filing
– Requested more details of the factors and specific plans
considered in support of the indefinite reinvestment assertion
– Requested a further explanation if the statement is made that it is
not practicable to estimate the unrecognized deferred tax liability
– Asked companies with significant unremitted foreign earnings to
explain what portion of their foreign earnings is kept in cash and
cash equivalents, and provide clarity as to whether these funds
might be subject to a significant tax cost upon repatriation
Transparency
What is the SEC doing about it
© Grant Thornton LLP. All rights reserved. 60
Transparency
What is the FASB doing about it
• FASB met on February 11, 2015 to review proposals to
improve disclosures related to foreign earnings
• FASB tentatively concluded that a reporting entity should be
required to:
– Separately disclose income before taxes between domestic and
foreign earnings (similar to the current SEC requirement)
• The entity should also be required to further disaggregate foreign
earnings, whether indefinitely reinvested or not, by jurisdictions that are
significant in relation to the total income before taxes
– Disclose separately the accumulated amount of indefinitely
reinvested foreign earnings for any foreign jurisdiction that represents
at least 10% of the total accumulated amount of indefinitely
reinvested foreign earnings
© Grant Thornton LLP. All rights reserved. 61
Transparency
What is the FASB doing about it
• FASB tentatively concluded that a reporting entity should be
required to (continued): – Disclose the following:
• Domestic tax expense recognized in the period for taxes on foreign
earnings, e.g., the incremental U.S. tax expense resulting in the current
period for foreign earnings not subject (or no longer subject) to the
indefinitely reinvested assertion
• Amounts during the current period that are no longer asserted to be
indefinitely reinvested*
• An explanation of the circumstances that caused the entity to no longer
assert that the earnings are indefinitely reinvested*
* For these items, the entity should also be required to provide separate disclosure of foreign
jurisdictions that are significant in relation to the total amounts being disclosed. Additionally,
the last item may be modified to also include an explanation of the circumstances that
caused the entity to assert that earnings, which were previously considered to not be
indefinitely reinvested, will now be indefinitely reinvested.
© Grant Thornton LLP. All rights reserved. 62
• Caution:– All decisions reached at FASB meetings are tentative and may be
changed at future meetings; decisions are included in an Exposure
Draft only after a formal written ballot. Decisions reflected in
Exposure Drafts are often changed in redeliberations by the Board
based on information received in comment letters, at public
roundtable discussions, and from other sources.
– Board decisions become final only after a formal written ballot to
issue a final Accounting Standards Update
Transparency
What is the FASB doing about it
© Grant Thornton LLP. All rights reserved. 63
Transparency
What you can do about it
• Take a fresh look at existing MD&A discussion and footnote
disclosures
• Go beyond boilerplate language to provide as much clarity
and transparency as possible to meet the needs of
investors and analysts, including:– How indefinitely reinvested foreign earnings impact reported
earnings, foreign and domestic liquidity needs, and foreign asset
composition (including cash)
– Even in advance of any FASB changes, consider a separate
disclosure by jurisdiction, if considered individually significant, of (1)
foreign earnings and (2) accumulated amount of indefinitely
reinvested foreign earnings. • Example of Apple's disclosure regarding Ireland in most recent Form
10-K (next slide)
© Grant Thornton LLP. All rights reserved. 6464
Example of Apple's disclosure regarding Ireland in Form 10-K
for the fiscal year ended September 27, 2014
Financial Statements Note 5
Substantially all of the Company’s undistributed international earnings
intended to be indefinitely reinvested in operations outside the U.S. were
generated by subsidiaries organized in Ireland, which has a statutory tax
rate of 12.5%. As of September 27, 2014, U.S. income taxes have not
been provided on a cumulative total of $69.7 billion of such earnings. The
amount of unrecognized deferred tax liability related to these temporary
differences is estimated to be approximately $23.3 billion.
Transparency
What you can do about it
© Grant Thornton LLP. All rights reserved. 65
Transparency
What you can do about it
• Use the income tax rate reconciliation, which shows the
effect of foreign earnings on the company’s effective tax
rate as a separate reconciling line item, as only a starting
point for the disclosure regarding foreign earnings– Review the tax workpapers to identify the various components
included in that reconciling line item for purposes of expansion of
the disclosure
– Examples of items that may warrant further disclosure include
permanent book-to-tax differences that caused a materially higher
or lower tax rate in foreign jurisdictions, significant portions of
foreign earnings generated in a particular tax jurisdiction, and
specific factors that caused any material year-over-year changes in
the percentage of pre-tax foreign earnings to total pre-tax earnings.
© Grant Thornton LLP. All rights reserved. 66
Transparency
What you can do about it
• In the MD&A section, consider discussing trends and
uncertainties that will inform investors about the companies’
expectations within specific countries
– This is particularly important if a substantial portion of the foreign
earnings is generated in a particular country, and the tax laws in that
country are subject to change. In that case, the potential risks may
become sufficiently significant to merit disclosure
– Consider "early warning" to users of your financial statements
• Examples of Apple's disclosure relating to Irish tax laws and Amazon's
disclosure relating to Luxembourg tax rulings (next slides)
© Grant Thornton LLP. All rights reserved. 6767
Example of Apple's disclosure relating to Irish tax laws in Form
10-K for the fiscal year ended September 27, 2014
Item 1A. Risk Factors
The Company could be subject to changes in its tax rates,
the adoption of new U.S. or international tax legislation or
exposure to additional tax liabilities.
The Company is subject to taxes in the U.S. and numerous foreign
jurisdictions, including Ireland, where a number of the Company’s subsidiaries
are organized…If the Company’s effective tax rates were to increase,
particularly in the U.S. or Ireland…the Company’s operating results, cash
flows and financial condition could be adversely affected.
Transparency
What you can do about it
© Grant Thornton LLP. All rights reserved. 6868
Example of Amazon's disclosure relating to Luxembourg tax
rulings in Form 10-K for the year ended December 31, 2014
• Background
– European Union (EU) is conducting a probe regarding Luxembourg tax
rulings; issue as to whether the rulings constitute illegal state aid
– Leaked documents show that billions of dollars in taxes have been
allegedly saved by hundreds of multinational corporations
– EU has stated it will not limit how much it seeks to claw back from
companies if the rulings are overturned
"The odds and stakes for the companies are massive…the concept of too big to fail in
terms of recovery doesn't exist"
Statement by Gert-Jan Koopman, EU's deputy-director for state aid (January 29, 2015)
Transparency
What you can do about it
© Grant Thornton LLP. All rights reserved. 6969
Example of Amazon's disclosure relating to Luxembourg tax
rulings in Form 10-K for the year ended December 31, 2014
Item 1A. Risk Factors
We Could be Subject to Additional Income Tax Liabilities
…in October 2014, the European Commission opened a formal investigation
to examine whether decisions by the tax authorities in Luxembourg…comply
with European Union rules on state aid. If this matter is adversely
resolved…we may be required to pay, additional amounts with respect to
current and prior periods and our taxes in the future could increase. Although
we believe our tax estimates are reasonable, the final outcome…could be
materially different from our historical income tax provisions and accruals.
Transparency
What you can do about it
© 2014 Grant Thornton LLP. All rights reserved. 70
Financial statement implications
• Transparency
• Risk management
© Grant Thornton LLP. All rights reserved. 71
Risk management
The issue• The changes in the global tax landscape may pose financial
statement risks including ultimately impacting the amount of
taxes paid on profits being shifted to foreign countries with
lower tax rates
"The structures could be sensitive to legal challenges or to changes
in the application of the rules, if not the rules themselves, issuers
may then face cash outflows related to the tax liabilities that were
until then exempt even from being recorded as a liability"
"Offshore Corporate Profits Pose Hidden Risks,"
CFO.com (June 6, 2014)
© Grant Thornton LLP. All rights reserved. 72
• Identify, evaluate and respond to the changes in the global
tax landscape including the managerial and financial
reporting implications of:
– BEPS Action Plan
• Consider using as a roadmap for the evaluation of current structures and
strategies which have the effect of base erosion and profit shifting even if
currently lawful
– Proposed legislation
• May require "early warning" to users of your financial statements
Risk management
What you can do about it
© 2014 Grant Thornton LLP. All rights reserved. 7373
• Identify, evaluate and respond to the changes in the global
tax landscape including the managerial and financial
reporting implications of:
– New legislation and regulations
• May require adjustment to estimated annual effective tax rates and re-
measurement of existing deferred tax assets and liabilities
• Non-compliance with FATCA requirements may result in exposures for missed
withholding taxes, interest and penalties
– More aggressive enforcement, settlement experience, and judicial
decisions
• May change recognition and measurement of unrecognized tax benefits
Risk management
What you can do about it
© 2014 Grant Thornton LLP. All rights reserved. 7474
• Have an effective internal control process with respect to the
identification, evaluation and mitigation of resulting risks
– Including on-going communications with the audit committee
• Have resource readiness to deal with:
– The expected increase in cross-border tax disputes
– The expected compliance burden relating to country-by-country
reporting of transfer pricing
– The potential increase in scrutiny of foreign earnings by your audit
firm (see next slide)
Risk management
What you can do about it
© 2014 Grant Thornton LLP. All rights reserved. 75
• Potential increase in scrutiny of foreign earnings by your
audit firm
– The Public Company Accounting Oversight Board (PCAOB)
recently expressed concerns about the audit work performed on
companies' foreign earnings
• As U.S. companies experience increasing profits in lower-taxed
jurisdictions, the undistributed earnings and cash held overseas raise
potential audit risks
• Audit work performed around significant tax structuring transactions is
a "heightened concern"
Comments by Helen Munter, director of the PCAOB Division of
Registration and Inspections, at an AICPA Conference on
December 10, 2014
Risk management
What you can do about it
© 2014 Grant Thornton LLP. All rights reserved. 76
Audience question 4
A. An increase in our effective tax rate and/or taxes paid
B. The lack of resources to identify, evaluate and respond to
the changes
C. Making the necessary changes to the design or operation of
our internal controls
D. Providing sufficient transparency to the users of our
financial statements
E. Other; I don't know
What is your biggest managerial or financial reporting
concern relating to the changing global tax
landscape?
© 2014 Grant Thornton LLP. All rights reserved. 77
Questions?Comments?
© 2014 Grant Thornton LLP. All rights reserved. 78
Randy Free
Partner, West Region
International Tax Practice
Leader
949.608.5311
randy.free@us.gt.com
Allan Smith
Partner, International Tax
408.216.8540
allan.smith@us.gt.com
InformationContact
© 2014 Grant Thornton LLP. All rights reserved.
Tangible Property
Regulations: Is Your Company Prepared?
© 2014 Grant Thornton LLP. All rights reserved. 80
Scott Hamilton
Director, Strategic Federal
Tax Services
213.596.8426
scott.hamilton@us.gt.com
PresenterToday's
© 2014 Grant Thornton LLP. All rights reserved. 81
Learning objectives
• Determine how the new
Tangible Property
Regulations impact
your company
• Determine how to
prepare for the
Tangible Property
Regulations
Tangible Property Regulations: Is Your Company Prepared?
© 2014 Grant Thornton LLP. All rights reserved. 82
Agenda
• What changed?
• Highlights of new regulations
• How do I deal with this?
© 2014 Grant Thornton LLP. All rights reserved.
Big Picture
© 2014 Grant Thornton LLP. All rights reserved. 84
New Law
Final regulations Final procedures
• TD 9636 — September 2013
• Amounts paid to acquire, produce
or improve tangible property,
selling costs and certain
depreciation
• Five elections with varying
procedures
• TD 9689 — August 2014
• Depreciation and dispositions
• Four elections with varying
procedures
• Rev. Proc. 2014-16 — January 2014
• Method changes for amounts paid to
acquire, produce or improve tangible
property
• Rev. Proc. 2014-17 — February 2014
• Method changes for depreciation
• Rev. Proc. 2014-54 — September 2014
• Method changes for depreciation and
dispositions
Action must be
taken for the
2014 taxable
year.
Effective now – For taxable years beginning on or after Jan. 1, 2014
© 2014 Grant Thornton LLP. All rights reserved. 85
Rev. Proc. 2014-16
DCN
Approx. §Description §481(a)
21
10.03(1)
Treatment of removal costs in disposal of a depreciable asset,
including a partial disposition. Treas. Reg. §1.263(a)-3(g)(2)(i)Yes
184
10.11(3)(a)(vi)
10.11(3)(a)(v)
Deducting repair and maintenance costs, or capitalizing
improvements to tangible property (and related depreciation, if
applicable). Includes change(s) to unit(s) of property and
removal costs related to property not disposed of. Treas. Reg.
§1.162-4; Treas. Reg. §1.263(a)-3
Yes
185
10.11(3)(a)(xi)
Change to the regulatory accounting method for determining
whether amounts paid to repair, maintain or improve property.
Treas. Reg. §1.263(a)-3(m)
2014
Cutoff
186
10.11(3)(a)(i)
Deducting non-incidental materials and supplies when used or
consumed. Treas. Reg. §§1.162-3(a)(1), (c)(1)
2014
Cutoff
187
10.11(3)(a)(ii)
Deducting incidental materials and supplies when paid or
incurred. Treas. Reg. §§1.162-3(a)(2), (c)(1)
2014
Cutoff
188
10.11(3)(a)(iii)
Deducting non-incidental rotable and temporary spare parts
when disposed. Treas. Reg. §1.162-3(a)(3), (c)(2)
2014
Cutoff
189
10.11(3)(a)(iv)
Change to the optional method for rotable and temporary spare
parts. Treas. Reg. §1.162-3(e) Yes
190
10.11(3)(a)(vii)
Deducting dealer expenses that facilitate the sale of property.
Treas. Reg. §1.263(a)-1(e)(2)Yes
191
10.11(3)(a)(viii)
Capitalizing non-dealer expenses to facilitate the sale of property.
Treas. Reg. §1.263(a)-1(e)(1)Yes
192
10.11(3)(a)(ix)
Capitalizing acquisition or production costs and, if depreciable,
depreciating such property under Section 167 or Section 168.
Treas. Reg. §1.263(a)-2
Yes
193
10.11(3)(a)(x)
Deducting certain costs for investigating or pursuing the
acquisition of real property. Treas. Reg. §1.263(a)-2(f)(2)(iii)
2014
Cutoff
194
11.09
Change to reasonable allocation method under §263A for self-
constructed assets. Treas. Reg. §1.263A-1(f)(4)Yes
195
11.10Change to stop capitalizing §263A to OREO Yes
Numerous Accounting Method
Changes (Form 3115)Rev. Proc. 2014-17 & 2014-54
DCN
Approx. §Description §481(a)
196
6.33Late partial disposition election. Treas. Reg. §1.168(i)-8 Yes
197
6.34Revocation of a general asset account election. Treas. Reg. §1.168(i)-1 Yes
198
6.35
Partial dispositions of tangible depreciable assets to which IRS's
adjustment pertains. Treas. Reg. §1.168(i)-8 Yes
199
6.36Depreciation of leasehold improvements. Treas. Reg. §1.167(a)-4 Yes
200
6.37
Permissible to permissible method of accounting for depreciation of
MACRS property (groupings). Treas. Reg. §§1.168(i)-1, 1.168(i)-7 and
1.168(i)-8
Mix
205
6.38
Disposition of a building or structural component, includes loss on
phantom assets still being depreciated. Treas. Reg. §1.168(i)-8Yes
206
6.39
Dispositions of tangible personal property depreciable assets, includes
loss on phantom assets still being depreciated.
Treas. Reg. §1.168(i)-8
Yes
207
6.40
Dispositions of tangible depreciable assets in a general asset account.
Treas. Reg. §1.168(i)-1Yes
© 2014 Grant Thornton LLP. All rights reserved. 86
Numerous Elections
Elections
GT Election No. Description Implementation §481(a)
Election 1Election to capitalize and depreciate rotable, temporary or emergency spare parts (on an asset by asset basis).
Treas. Reg. §1.162-3(d)Made by doing it N/A
Election 2 De minimis safe harbor election to follow book expensing of tangible property. Treas. Reg. §1.263(a)-1(f)Annual statement
in returnN/A
Election 3Election to capitalize employee compensation and/or overhead as facilitating the acquisition of property (on
asset-by-asset basis, for either employee compensation, overhead or both). Treas. Reg. §1.263(a)-2(f)(2)(iv)Made by doing it N/A
Election 4 Election to capitalize all otherwise deductible repairs that are capitalized for book. Treas. Reg. §1.263(a)-3(n)Annual statement
in returnN/A
Election 5Small taxpayer safe harbor election to not apply improvement rules.
Treas. Reg. §1.263(a)-3(h)
Annual statement
in returnN/A
Election 6Election to recognize gain/loss on partial dispositions of assets (non-GAA property; asset-by-asset basis).
Treas. Reg. §1.168(i)-8(d)Made by doing it N/A
Election 7 General asset account election for current-year property placed in service. Treas. Reg. §1.168(i)-1(l)Annual Form 4562,
Line 18N/A
Election 8Optional termination of a GAA at disposition of all assets in the GAA.
Treas. Reg. §1.168(i)-1(e)(3)(ii)Made by doing it N/A
Election 9Optional recognition of a qualifying disposition of an asset within a GAA.
Treas. Reg. §1.168(i)-1(e)(3)(iii)Made by doing it N/A
© 2014 Grant Thornton LLP. All rights reserved. 87
Polling question
What have you done to prepare for the Tangible Property
Regulations?
A. Completed assessment and full study, with 3115's and
necessary elections
B. Started assessing their impact
C. Nothing, but we need to do something
D. Does not apply (are you sure?)
© 2014 Grant Thornton LLP. All rights reserved.
Highlights of the Tangible
Property Regulations
© 2014 Grant Thornton LLP. All rights reserved. 89
Overview of Law
De minimisMaterials and
supplies Acquisitions Depreciation Improvements Dispositions
• Annual election for de
minimis safe harbor to
expense assets
expensed pursuant to
book procedures in
place at beginning of
the year
- For assets ≤ $5,000 if
have Applicable
Financial Statements
(AFS) and if book
procedures are written
- For assets ≤ $500 if
no AFS
- Includes repairs and
materials and supplies
• Definition
- A unit of property
≤ $200
- Used or consumed
in 12 months or less
- Replacement parts
- Fuel, lubricants, etc.
or
- Identified in other
IRS guidance
• Types and timing
- Incidentals - when
acquired
- Non-incidentals,
generally - when
consumed
- Rotable and temporary
spare non-incidental
parts - when disposed
• Annual election to
capitalize a rotable,
temporary or
emergency spare part
• Capitalize costs that
facilitate acquisitions
- 11 inherently
facilitative costs
- Certain investigatory
costs for real property
are not capital
- Expense employee
compensation and
overhead
- Annual election to
capitalize employee
compensation and/or
overhead
• Capitalize costs that
defend or perfect title
• Depreciation of
leasehold
improvements is
MACRS recovery
period not over term of
lease
• Multiple asset
accounts and single
asset accounts
• General asset account
(GAA) annual election
• Unit of Property definition
- Buildings
- Plant property
- Leased property
- Network assets
- Other property, e.g.,
• Other personal
property
• Other land
improvements
• Improvement defined
- Betterment
- Restoration
- New or different use
- Routine maintenance
• Annual election to
capitalize otherwise
deductible repairs that
are capitalized for book
• Annual election for small
taxpayer to not apply
improvement rules
• Optional method for
certain regulated assets
• Dispositions
- Annual election to
recognize partial
dispositions (e.g.,
building components)
- Reasonable methods
to determine asset
disposed
- Reasonable valuation
method to determine
basis for gain or loss
- Coordination with IRS
examination of repairs
- GAA two annual
elections for
dispositions
• Differing treatment of
certain selling expenses
for property for which
the taxpayer is a dealer
versus nondealer
© 2014 Grant Thornton LLP. All rights reserved. 90
New annual election.
Allows taxpayers to
follow book policy in
expensing de minimis
assets.
• Procedures must be in writing for
taxpayers with "applicable financial
statements"
• Election needs to be made each year by
filing a statement with the return
• Election applies to all eligible materials
and supplies
• May need to document clear reflection of
income for amounts expensed over safe
harbor
ElectionDe minimis safe harbor
© 2014 Grant Thornton LLP. All rights reserved. 91
De Minimis Safe Harbor Election
• An Applicable Financial Statement (AFS) is:
– for Securities and Exchange Commission;
– certified audited financial statement that is
accompanied by the report of an independent CPA
used for credit purposes, reporting to
shareholders, partners or similar persons; or
– A financial statement required to be provided to a
government agency
© 2014 Grant Thornton LLP. All rights reserved. 92
De Minimis Safe Harbor Election
Requires:
• Written accounting policy in place at beginning of year
• Policy is to expense property costing less than a
certain dollar amount or property with economic useful
life of 12 months or less.
• Taxpayer actually deducts such amounts in financial
statements
• Amount paid does not exceed $5,000 or $500 per
invoice (or per item as substantiated by invoice)
© 2014 Grant Thornton LLP. All rights reserved. 93
Page 17
• New definition of what is
"material and supply"
• New rules and election
for rotable and temporary
spare parts
• New definition likely requires filing a Form 3115,
especially if have Balance Sheet account
• New rule that rotable and temporary spare parts
are not deductible until when disposed may
require filing a Form 3115
• Alternatively, may use optional method, which
also requires a Form 3115
• Alternatively, may elect to capitalize and
depreciate, which does not require a statement
Materials and Supplies
Form 3115 and election
© 2014 Grant Thornton LLP. All rights reserved. 94
Materials and Supplies
• If you do not take the De Minimis election, then you must define your Materials and Supplies as:
– Components acquired to maintain, repair, or improve a unit of tangible property owned, leased, or serviced by the taxpayer that is not acquired as part of any single unit of property
– Fuel, lubricants, water and similar items expected to be consumed in 12 months or less
– Property with economic useful life of 12 months or less
– Property with acquisition cost of $200 or less
© 2014 Grant Thornton LLP. All rights reserved. 95
Materials and Supplies
• Non-incidental supplies
– Deductible in the year in which the materials are first used or consumed in the taxpayer's operations
• Incidental supplies
– Deductible in the year in which amounts are paid
– Materials and Supplies for which there is a Balance Sheet account are not "incidental"
Incidental supplies are those for which no record of consumption is kept or physical inventories at beginning and end of year are not taken
© 2014 Grant Thornton LLP. All rights reserved. 96
• When acquiring new property,
TPR's list 11 "inherently
facilitative" costs that must be
capitalized
• New bright line date for
expensing certain
investigatory costs for real
property
• New annual election to
capitalize employee
compensation and/or
overhead
• New list of 11 inherently facilitative costs
may require filing a Form 3115; book may
not be including all costs in the list
• New bright line date for expensing certain
investigatory costs related to real property
may require filing a Form 3115
• Election to capitalize and depreciate
employee compensation and/or overhead
does not require a statement
Acquisition of Tangible Property
Form 3115 and election
© 2014 Grant Thornton LLP. All rights reserved. 97
Acquisitions
• For this, a taxpayer must generally capitalize:
(1) invoice price;
(2) transaction costs;
(3) cost of work performed prior to the date placed in service; and
(4) amount paid to defend or perfect title.
• Amounts that facilitate the acquisition or production must be capitalized, including inherently the 11 inherently facilitative costs.
© 2014 Grant Thornton LLP. All rights reserved. 98
• Transporting the property (shipping fees and moving costs)
• Securing an appraisal or determining the value or price of property
• Negotiating the terms or structure the acquisition and obtaining tax advice on the acquisition
• Application fees, bidding costs, or similar expenses
• Preparing and reviewing the documents that effectuate the acquisition of the property (for example, preparing the bid, offer, sales contract, or purchase agreement);
• Examining and evaluating the title to property
• Obtaining regulatory approval of the acquisition or securing permits related to the acquisition
• Conveying property between parties, including sales and transfer taxes, and title registration costs
• Finders' fees and brokers' commissions, including contingency fees
• Architectural, geological, survey, engineering, environmental, or inspection services pertaining to a particular properties
• Services provided by a qualified intermediary or other facilitator in an exchange under 1031
Acquisitions
© 2014 Grant Thornton LLP. All rights reserved. 99
• New definition of Unit of
Property (UOP)
• New rules for determining
whether there is a capital
improvement
• New annual election to
capitalize otherwise
deductible repairs that are
capitalized for book
• New definition of unit of property likely
requires filing a Form 3115
• New rules for determining whether there is a
capital improvement likely requires filing a
Form 3115, even if followed book in past
• Election to capitalize otherwise deductible
repairs that are capitalized for book requires
annual statement with return
Improvements
Form 3115 and election
© 2014 Grant Thornton LLP. All rights reserved. 100
Unit of property defined
Building systems include:
- HVAC systems - Fire protection and alarm systems
- Plumbing systems - Security systems
- Electrical systems - Gas distribution systems
- All escalators - Any other structural components
- All elevators in published guidance
© 2014 Grant Thornton LLP. All rights reserved. 101
General Rule
A taxpayer must generally capitalize an amount that
IMPROVES a unit of property ("UOP") if the amount:
(1) Is for a betterment;
(2) Restores the UOP; or
(3) Adapts the UOP to a new or different use.
© 2014 Grant Thornton LLP. All rights reserved. 102
1) Betterment
– Ameliorates a material condition or defect that either
existed prior to the Taxpayer's acquisition of the property
or arose during production of the UOP;
Example: Sally buys a building knowing it has an old leaky
roof. She then has the roofing membrane redone. This is a
betterment (capitalize).
Example: Phil buys a building with a functioning roof. After
10 years, he has the roofing membrane repaired. This is not
a betterment (deduct).
© 2014 Grant Thornton LLP. All rights reserved. 103
1) Betterment
– Results in a material addition to or addition of a major
component to the UOP, or a material increase in the capacity of
the UOP;
Example: Bob has a warehouse. He needs more space and so
builds an expansion to the warehouse. This is a betterment
(capitalize).
– Results in a material increase in productivity, strength, efficiency,
or quality of the UOP or the output of the UOP.
Example: Fred has an old A/C system that needs a new
compressor. He replaces the old compressor with a brand new
higher rated and more efficient compressor. This is a betterment
(capitalize).
© 2014 Grant Thornton LLP. All rights reserved. 104
2) Restoration
An amount restores property if the amount:
1) Results in the rebuilding of the UOP to a like-new condition after
the end of its class life;
2) Is for the replacement of a part or a combination of parts that
comprise a major component or a structural part of the UOP;
3) Returns the UOP to its ordinarily efficient operating condition if
the property has deteriorated to a state of disrepair and is no
longer functional for its intended use;
© 2014 Grant Thornton LLP. All rights reserved. 105
2) Restoration – new examples
Restoration
(capitalize)• 1 chiller in HVAC system
• Entire sprinkler system
• All wiring in building
• All restroom fixtures
• 200 of 300 windows
• 100 of 300 windows (windows cover 90% of building)
• 40% of sq ft of flooring
Not a restoration
(deduct)• 1 of 3 furnaces
• 3 of 10 roof HVAC units
• 30% of electrical wiring
• 8 of 20 sinks
• 100 of 300 windows (300 windows cover 25% of building surface area)
• 10% of sq ft of flooring
• 1 of 4 elevators
© 2014 Grant Thornton LLP. All rights reserved. 106
Election to capitalize repair and
maintenance costs
• Taxpayer's may elect to capitalize amounts incurred
during the year as costs of improvements if TP
capitalizes the amounts on its books and records
• Election applies to all amounts treated as capital for
books each year
• Election made by attaching a statement to the return
each year
© 2014 Grant Thornton LLP. All rights reserved. 107
• New annual election to
recognize losses on partial
dispositions
• One-time retroactive
election for partial
dispositions in prior years
• New rules for determining
reasonable method for
which unit disposed and its
basis
• Current-year election to recognize partial
disposition does not require statement
• Retroactive partial disposition requires filing a
Form 3115 and is time-limited
• New rules for determining which unit disposed
and its basis may require filing a Form 3115,
depending upon prior methods
• Unrecovered basis on certain assets disposed
in prior years requires filing a Form 3115
Dispositions
Form 3115 and election
© 2014 Grant Thornton LLP. All rights reserved. 108
Dispositions
• Taxpayer may elect to dispose (sale, abandonment,
etc.) of a portion of an asset. Includes:
– Structural components (or components thereof) of a
building
– Components or portions of personal property assets
• Partial disposition (other than required situations) is a
not a method of accounting.
• Election is made in year of partial disposal by taking the
deduction on the year's return
© 2014 Grant Thornton LLP. All rights reserved. 109
Late Partial Disposition Election
• One-time retroactive election for partial dispositions in
prior years
• Retroactive partial disposition requires filing a Form
3115 and is time-limited.
• The retroactive election must be made for taxable
years beginning before Jan. 1, 2015.
© 2014 Grant Thornton LLP. All rights reserved. 110
Polling question
Do you think you will take advantage of the last
chance to accelerate recovery of basis for late
partial dispositions in prior years?
A. Yes
B. No
C. Not sure yet
© 2014 Grant Thornton LLP. All rights reserved. 111
Planning opportunities
Significant opportunities
• Section 481(a) adjustment for deducting
repairs (capture missed repairs expenses)
• Section 481(a) adjustment for retroactive
partial dispositions election (for 2014 only)
• Fixed asset scrub (clean up)
• Cost segregation study
• Identify phantom assets
• Outsource fixed asset schedule maintenance
Retroactive partial
disposition election
is a time-limited
opportunity
© 2014 Grant Thornton LLP. All rights reserved.
Assessing The Impact
© 2014 Grant Thornton LLP. All rights reserved. 113
Assessment
Final Regulations
are here
Look at your current
methods
Assess the
impact
Many of the accounting methods and elections are interrelated,
and therefore affect each other.
© 2014 Grant Thornton LLP. All rights reserved. 114
What are you doing?
© 2014 Grant Thornton LLP. All rights reserved. 115
Example: SuperTech, Inc.
Super Tech Inc. is a company based in Mountain View,
California. Private company with 12/31 TYE.
Super Tech has 5 office locations in the Western U.S.
The Company has not addressed the new Tangible
Property regulations. The Company has an accounting
policy in place that capitalizes tangible property above
$5,000. The Company currently follows its book for all
improvement/repair expenditures.
© 2014 Grant Thornton LLP. All rights reserved. 116
Deducting R&M costs and
Capitalizing Improvements
© 2014 Grant Thornton LLP. All rights reserved. 117
Assessment Summary Report
© 2014 Grant Thornton LLP. All rights reserved. 118
Implementation considerations
Compliance• Tax provision
• Current-year implementation
• Section 481(a) adjustments
• Impact on other federal computations, e.g.,
Section 199 deduction, Section 263A, etc.?
• State and local taxes
• Earnings and profits for CFCs
• Tax return disclosures
• Forms 3115
• Election statements
• When will we get this done?
• How do we efficiently comply?
• How do we efficiently document for IRS exam?
• What elections must be done annually going
forward?
Next steps Complete assessment
© 2014 Grant Thornton LLP. All rights reserved. 119
Polling question
A. Complexity and breadth of regulations
B. Coordination to obtain information regarding current policies
(between differing subsidiaries)
C. Amount of time needed for full implementation
D. Other; I don't know
What do you think will be the biggest challenge you
will face relating to full implementation of the Tangible
Property Regulations for your 2014 return?
© 2014 Grant Thornton LLP. All rights reserved. 120
Doing nothing?
• Consider the risks:
– Incorrect depreciation on tax return
– Use of improper methods
– Correlative adjustments to permanent items
– Return-signing concerns
– Potential IRS examination issues
– Financial statement implications
© 2014 Grant Thornton LLP. All rights reserved. 121
Summary
• Tangible Property Regulations are not optional
• Lease or own – doesn't matter
• Consider assessing the regulations first
• Then select your elections and method changes
• Could be some additional tax benefits along the way
© 2014 Grant Thornton LLP. All rights reserved. 122
Questions?Comments?
© 2014 Grant Thornton LLP. All rights reserved. 123
Scott Hamilton
Director, Strategic Federal
Tax Services
213.596.8426
scott.hamilton@us.gt.com
InformationContact
© 2014 Grant Thornton LLP. All rights reserved. 124
Disclaimer
This Grant Thornton LLP presentation is not a comprehensive analysis of the subject matters covered and may include proposed guidance that is subject to change before it is issued in final form. All relevant facts and circumstances, including the pertinent authoritative literature, need to be considered to arrive at conclusions that comply with matters addressed in this presentation. The views and interpretations expressed in the presentation are those of the presenters and the presentation is not intended to provide accounting or other advice or guidance with respect to the matters covered.
For additional information on matters covered in this presentation, contact your Grant Thornton, LLP adviser.
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